Recent press regarding CRTs and CRT glass has called attention to a serious and growing concern: How to responsibly process all the end of life CRTs that are out there?
The system has been overwhelmed by a combination of factors, most notably increased costs associated with responsible management and the swift market transition to flat-screen displays. The current situation has highlighted a number of issues for electronics recycling certification programs - issues that come up with respect to the management of CRTs but are not exclusive to CRTs.
For example, given the backlog of CRTs awaiting processing, or abandoned, there are warehouses full of them. CRTs cannot remain stored indefinitely or they are deemed "speculatively accumulated" and trigger significant RCRA requirements [40 CFR 261.4(a)(22)].
How to avoid this? CRTs and CRT glass are not speculatively
- There is a feasible means of recycling the CRTs or CRT glass, and
- At least 75 percent of each CRT material is either recycled or transferred for recycling during the calendar year. (40 CFR 261.1(c)(8))
Recyclers and auditors need to understand and live by these regulations. Speculative accumulation constitutes a non-conformance with the R2 Standard (as do all violations of such laws and regulations). For more information, please visit: http://www.epa.gov/osw/hazard/recycling/electron/crt-faq.htm.
Also an issue for auditors and Certification Bodies is identifying these warehouses - it is not a straightforward matter to identify an undisclosed warehouse based on a review of processing systems and records. Auditors need to press recyclers for full disclosure of all buildings related to their business. And anyone that learns of a certified recycler running "dual" businesses or otherwise hiding operations or material needs to share this information with the appropriate Certification Body. R2 Solutions increasingly is getting this sort of information, which we pass on to the Certification Bodies to address.
Another issue raised by the current CRT situation is the need for strong closure plans and fully sufficient financial instruments. It is easy to underestimate the cost and requirements involved in cleaning up a warehouse full of abandoned CRTs. Auditors and recyclers need to take these certification requirements seriously and address them fully.
And, of course, the most pressing issue related to CRTs, that also is potentially associated with other materials and processing, is the serious health threats posed by types of worker exposures to some materials, particularly lead. We are just learning what some of the exposure vectors are and when action is required. For both auditors and recyclers, there is a need to keep abreast of the latest research and to apply certification requirements in light of the latest information.